E-Invoicing in Denmark

Mandatory Electronic Invoicing in Denmark

Learn how to get your company ready to exchange documents in accordance with regulations in Denmark

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Denmark on the Road to B2B E-invoicing

Denmark is no newcomer in the world of e-invoicing - since 2005 it has been mandatory in the public sector (B2G) for both public administrations and their suppliers (issuing for all suppliers for all contracting work, and receiving for all authorities). In B2B relations, these issues are only now being regulated.

Implementation timeline

B2B e-Invoicing in Denmark will follow the timeline below

January 2023

By that time, the detailed requirements will have to be published by the Danish Business Authority. System suppliers must then adapt their products to the new regulations and apply to the Agency for approval of their systems.

January 2024

The requirement for companies to use an approved system (accounting classes B, C and D).

January 2026

This requirement will also apply to personally owned accounting class A companies with a turnover of more than DKK 300,000.

Sole proprietorships with a turnover of less than DKK 300,000 will be exempt from the requirement to use a digital accounting system, but of course must still comply with all other requirements of the law.

Why is Comarch the best choice?

  • 1. You can be fully compliant with all local requirements and e-archiving rules in Denmark

    Comarch is compliant with all e-archiving processes of validations and files needed to be stored for the 5 year period. 

  • 2. You can achieve full legal compliance in more than 60 countries using just one tool

    Comarch is supporting many companies in becoming compliant with the document & data exchange regulations, so they can focus on their core business. We are a certified provider in many countries around the world, including Italy. 

  • 3. You can take advantage of high flexibility and customized services

    Comarch is able to provide multichannel flexibility and the possibility to customize products to meet your business needs.

  • 4. You will be supported by a global, experienced, and trustworthy player on the EDI market

    Comarch has over 20 years of experience in carrying out global EDI & document exchange projects. During that time, we have connected 130 000 entities from more than 60 countries.


    There is a centralized model that also supports the PEPPOL system. The whole system is supported by the official NemHandel platform.

    What is the NemHandel platform?

    It is a common public digital infrastructure for the exchange of business documents between private companies and public authorities. Since 2005, it has been required by law for Nemhandel to be used for the exchange of business documents with the authorities in Denmark.

    To send and receive digital business documents via Nemhandel platform, your accounting system must be connected to an access point. An access point ensures that the data that enters Nemhandel platform from an accounting system complies with the necessary security standards.

    PEPPOL in Denmark

    PEPPOL is a set of artifacts and specifications enabling cross-border e-procurement.

    The Danish Business Authority (ERST) is the PEPPOL Authority, which means that ERST is responsible for the registration of companies that wish to become a PEPPOL Access Point or a Service Metadata Publisher. ERST is also responsible for ensuring the long-term adoption of e-procurement using the PEPPOL network as the platform.

    What is the required format of an e-invoice?

    The formats that are supported are OIOUBL and PEPPOL BIS.

    Automatic business reporting - digital accounting system

    Automated business reporting means that companies must use an approved digital accounting system, and all electronic invoices must go through a central receiving portal in the same way as sending an e-invoice to the public sector today. A digital accounting system can be:

    • A cloud-based system where your business records its transactions and stores receipts. All of this must then be stored by a third party, either a system provider such as Comarch or on the provider's host. 
    • A hybrid system that is installed locally in your business, but has a built-in feature that automatically takes copies of registrations and documents, which are then stored with a third party. 
    • Specially developed systems where records and attachments are stored only on your company's own server, but where it is ensured that backups are made on an ongoing basis and that these backups are also stored at a third party.

    If your company does not use an approved, registered system, the system your company uses must meet the same requirements.

    Archiving requirements for e-invoicing in Denmark

    Companies must store accounting materials securely for a period of five years after the end of the financial year to which the material relates. As a matter of some interest, the requirement to retain accounting materials in Denmark has been abolished. 

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    Frequency of book-keeping and reconciliations

    Companies are required to record all transactions accurately and as soon as possible after the conditions on which the recording is based have been established.

    Companies which, due to their complexity, the number of transactions or the financial size of the transaction, are not in a position to record all individual purchases or sales, may instead record aggregate purchases or sales on the basis of daily cash statements.

    Companies are required to secure a control track, which can be documented with attachments and include references to this. Each registration must include information on its temporal location in the accounts. Attachments must contain the information necessary to identify the control track, including clearly indicating the date and value of the transaction. If the registration is based on external attachments, reference must be made to this.

    For years, we have been helping companies from many different industries operating in countries where e-invoicing has become obligatory (such as France, Spain, Germany, Turkey and Italy) and those where such an obligation will be introduced (for example, Poland). What is especially important here is that Comarch’s e-invoicing solution is fully compliant with the latest legal regulations and modern data transfer standards.

    Learn more about Comarch Data Exchange Solutions 

    How can we help?

    Join the companies that have already improved their data efficiency with Comarch e-Invoicing!

    Comarch has many years of experience in providing innovative IT products and services allowing for efficient document management and automation of various supply chain processes.

    Check out some of our success stories to learn what our clients have achieved by using Comarch EDI, MDM, e-Invoicing (also in a Cloud), and Online Distribution.

    Characteristics of the e-invoicing in Denmark

    Transactions with public entities must be documented by electronic invoices.

    In the B2B sector, e-invoicing is still voluntary but both parties can do so if they agree.

    E-invoice format and platform

    The European standard on e-invoicing is fully implemented under UBL 2.1.

    Platform: NemHandel and Peppol network

    Digitization of accounting

    It is worth mentioning that, in May 2022, the Danish parliament passed a package of reforms affecting the Danish Bookkeeping Act (‘DBA”) which states the obligation to keep and archive accounts in digital format. The new obligation will be implemented gradually.

    On the basis of DBA, all companies, regardless of size, that are obliged to submit an annual report and report it to the Danish Business Authority, will be covered by the new rules on book-keeping via a digital book-keeping system from 1 January 2024.

    Other companies subject to book-keeping, including personally owned companies, associations, branches and others that are not obliged to submit an annual report and report it to the Danish Business Authority, but have a turnover above DKK 300,000 two years in a row, will be covered by the new rules on book-keeping via a digital bookkeeping system from 1 January 2026.


    Storage period: 5 + 1 years

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